Privacy
Policy

This Privacy Policy describes how Sports Gear Exchange Ltd. ("Hockey Gear Exchange," "we," "us," or "our"), operating as Hockey Gear Exchange, collects, uses, and discloses personal information when you use our platform (the "Platform").

We are committed to protecting your privacy in compliance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation, as well as Canada's Anti-Spam Legislation (CASL).

By using the Platform, you consent to the collection, use, and disclosure of your personal information as described in this Policy. If you do not agree, please do not use the Platform.

We collect only the information necessary to provide the Platform. Here is a complete inventory:

Account Information (Account Holder)

Player Profiles (Entered by Account Holder on Behalf of Their Child)

Player profile information is entered by the adult account holder. See Section 8 (Children's Privacy) for more detail.

Gear Listings

When you post a listing, we collect the item category, brand, size, condition, price (or trade preference), description, and any photos you upload. Listings are visible to other members within your association.

Messages

When you use the Platform's messaging feature, we store the content of messages between users. Messages are associated with your account and the relevant listing.

Technical & Usage Data

We collect standard operational data, including login timestamps and account creation dates. We do not log IP addresses as part of our standard data collection practices.

We use the personal information we collect for the following purposes:

• Providing the Platform: Creating and managing your account, displaying listings within your association, enabling messaging between users, and supporting player profile gear matching.
• Transactional communications: Sending you a welcome email when you register and password reset emails when requested. These communications are necessary for the operation of your account.
• Account security: Detecting and preventing unauthorized access, fraud, and abuse.
• Platform improvement: Understanding how the Platform is used (using aggregated, non-identifiable data) to improve features and user experience.
• Legal compliance: Meeting our obligations under applicable Canadian law.
• Marketing communications: Only if you have given separate, explicit consent under CASL (see Section 9).

We will not use your personal information for any purpose that is incompatible with the purposes for which it was collected, unless we obtain your consent or are otherwise permitted by law.

• Payment or financial information — all transactions occur outside the Platform between buyers and sellers directly. Hockey Gear Exchange never touches payment data of any kind.
• Home or mailing addresses
• Phone numbers
• Full date of birth for players (we collect birth month only)
• Government identification
• Social insurance numbers or tax identifiers
• Biometric data

We do not sell your personal information. We share it only in the following limited circumstances:

Within Your Association

Your name and gear listings are visible to other members of your hockey association on the Platform. Your player profiles and account details are not shared with other users; only your name and listing content are visible.

Third-Party Service Providers

We share information with service providers who help us operate the Platform, as described in Section 6. These providers are contractually bound to handle your information only as instructed by us and in compliance with applicable privacy law.

Legal Requirements

We may disclose personal information if required to do so by law or in response to a valid legal process (such as a court order or government request), or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.

Business Transfers

If Hockey Gear Exchange is involved in a merger, acquisition, or sale of assets, your personal information may be transferred as part of that transaction. We will notify you by email and/or a prominent notice on the Platform before your information becomes subject to a different privacy policy.

We currently rely on the following third-party service providers:

Resend

We use Resend to deliver transactional emails (welcome emails and password reset emails). When we send you an email, your email address and the content of that email are processed by Resend as a data processor on our behalf. Resend does not use your data for its own marketing purposes. For more information, see Resend's Privacy Policy.

Supabase

We use Supabase as our database and backend infrastructure provider. All Platform data — including account information, player profiles, listings, and messages — is stored on Supabase's infrastructure. Supabase acts as a data processor on our behalf and does not use your data for its own purposes.

Please note that Supabase's infrastructure is primarily located in the United States. See Section 7 (Cross-Border Data Transfers) for what this means for your information.

Hockey Gear Exchange is a Canadian company. However, because our database infrastructure (Supabase) and email delivery provider (Resend) operate servers located in the United States, your personal information may be transferred to and stored in the United States.

The United States has different privacy laws than Canada. When your data is stored in the US, it may be subject to lawful access by US government authorities under US law.

By using the Platform, you consent to this cross-border transfer of your personal information. We take steps to ensure that your information is handled with an equivalent level of protection to that required under Canadian law, including through contractual obligations with our service providers.

Hockey Gear Exchange is designed for hockey families. All accounts are held by adults (18+) — the parent or legal guardian. Children do not create or hold their own accounts.

Player profile information (player name, birth month, year level, position, equipment sizes) is entered by the adult account holder on behalf of their child. The adult account holder is the data subject for consent purposes, and their consent covers the incidental collection of their child's profile information.

We do not knowingly collect personal information directly from children under 13 without verifiable parental consent. Player profiles are created and managed by parents — not by the children themselves.

If you believe that a child's information has been collected without appropriate parental consent, please contact us at hello@hockeygearexchange.ca and we will promptly investigate and take appropriate action.

Canada's Anti-Spam Legislation (CASL) governs commercial electronic messages. We comply with CASL as follows:

Transactional Messages (No Consent Required)

We send the following messages as part of operating your account, which are exempt from CASL's consent requirements:

• Welcome emails upon account creation;
• Password reset emails; and
• Notifications directly related to your account or Platform activity.

Marketing Messages (Consent Required)

We will only send you marketing or promotional messages (e.g., new features, association announcements, or newsletters) if you have given explicit consent at signup or subsequently opted in. Your consent is recorded with a timestamp in our system.

You may withdraw consent for marketing messages at any time by clicking the unsubscribe link in any marketing email or by contacting us at hello@hockeygearexchange.ca. Withdrawal of consent does not affect transactional messages necessary to operate your account.

We retain your personal information for as long as your account is active or as needed to provide the Platform. Specifically:

• Active accounts: All account data is retained while your account remains open.
• Closed accounts: Upon account closure, we will delete or anonymize your personal information within a reasonable time, subject to any legal obligations to retain certain records.
• Listings: Sold or removed listings may be retained in an anonymized or aggregated form for platform analytics.
• Messages: Messages are retained while both parties' accounts remain active. Messages may be deleted upon account closure.

If you would like your data deleted before closing your account, please contact us at hello@hockeygearexchange.ca.

Under Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), you have the following rights regarding your personal information:

• Access: You may request access to the personal information we hold about you.
• Correction: You may request that we correct inaccurate or incomplete information. You can update most account information directly within the Platform.
• Withdrawal of consent: You may withdraw your consent to the collection, use, or disclosure of your personal information, subject to legal or contractual restrictions. Withdrawal may limit or prevent your use of the Platform.
• Deletion: You may request deletion of your personal information, subject to our legal obligations to retain certain records.
• Complaint: If you believe we have not handled your personal information in compliance with PIPEDA, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada.

To exercise any of these rights, please contact our Privacy Officer at hello@hockeygearexchange.ca. We will respond within 30 days.

We implement reasonable administrative, technical, and physical safeguards to protect your personal information against unauthorized access, use, disclosure, or destruction. These measures include:

• Passwords stored as one-way cryptographic hashes (we cannot read your password);
• Authenticated API access with signed JSON Web Tokens (JWT);
• HTTPS encryption for all data in transit; and
• Access controls limiting which personnel can access account data.

No system is completely secure. We cannot guarantee that unauthorized third parties will never be able to circumvent our security measures. If you believe your account has been compromised, contact us immediately at hello@hockeygearexchange.ca.

We may update this Privacy Policy from time to time. When we make material changes, we will notify registered users by email and update the "Effective" date at the top of this page. Your continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy.

If we intend to use or disclose your personal information for purposes materially different from those described in this Policy, we will obtain your consent before doing so.

For privacy questions, access requests, complaints, or to exercise any of your rights under PIPEDA, please contact our Privacy Officer:

Privacy Officer
Sports Gear Exchange Ltd.
Operating as Hockey Gear Exchange
hello@hockeygearexchange.ca

We will acknowledge your request within 5 business days and respond fully within 30 days. If your request is complex, we will notify you if additional time is required.